The LTR 3219A is a variant within the LTR 3219 family of statutory notices of deficiency. The IRS uses different suffix letters (3219, 3219A, 3219B, 3219C) for different processing tracks, but the legal effect is identical across all variants. You have 90 days (150 days if abroad) to petition the United States Tax Court.
Why Multiple Variants Exist
The IRS generates statutory notices through different functions: examination, automated underreporter, appeals, and others. Each function may use a different letter variant. The suffix doesn't change your rights, your deadline, or the consequences of missing it.
The 90-Day Deadline
This deadline is identical across all LTR 3219 variants. It's jurisdictional. The Tax Court cannot accept a late petition. No extensions. No exceptions. Count 90 days from the notice date (not the date you received it) and have your petition filed before that date.
What to Do
Call a tax attorney immediately. The petition must be properly drafted, filed with the correct court, and served on the IRS Chief Counsel. Preparing a Tax Court petition takes time. Don't wait until week 12 to start looking for help.
If you've received any variant of the LTR 3219, call us today at (813) 229-7100. The clock is already running.